State v. Mbodji, 129 Ohio St. 3d 325

Mbodji charged with domestic violence (first degree misdemeanor) in Hamilton County Municipal Court.
Katrina McCall, private citizen, filed affidavit and complaint with clerk without reviewing official review.
Clerk issued arrest warrant without forwarding to reviewing official; no review occurred before filing.
Mbodji was arrested, pleaded not guilty, and proceeded to bench trial resulting in conviction and community-control sentence.
Court of Appeals affirmed; Mbodji argued lack of reviewing official violated R.C. 2935.09 and affected jurisdiction.
This lead to Supreme Court of Ohio review of whether lack of review affects trial court subject-matter jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether lack of reviewing official review under R.C. 2935.09 affects jurisdiction.	Mbodji argues lack of review voids jurisdiction.	McCall argues filing complied with Crim.R. 3; jurisdiction invoked.	Not jurisdictional; Crim.R. 12(C) remedy available.
Does Crim.R. 3 filing by private citizen invoke trial court jurisdiction.	Mbodji asserts defect shows no valid complaint.	Complaint valid under Crim.R. 3; invoked jurisdiction.	Complaint valid; invoked court jurisdiction.
Remedy for noncompliance with R.C. 2935.09 before trial.	Crim.R. 12(C) not pursued; defect waived.	Procedural defect remediable under Crim.R. 12(C).	Defect is subject to Crim.R. 12(C); not jurisdictional; waiver if not raised.

State v. Miller, 47 Ohio App.3d 113 (1988) (filing of complaint invokes municipal court jurisdiction)
State v. Craig, 1986 WL 3096 (Ohio App. 1986) (Crim.R. 3 requirements for valid complaint)
Pratts v. Hurley, 102 Ohio St.3d 81 (2004) (definition of jurisdiction; subject-matter jurisdiction cannot be waived)
State v. Holbert, 38 Ohio St.2d 113 (1974) (personal jurisdiction waivable vs. subject-matter)
State v. Williams, 51 Ohio St.2d 112 (1977) (waiver of defenses if not raised timely)
State v. Carter, 89 Ohio St.3d 593 (2000) (Crim.R. 12(H) waiver principle)